Tooby's California Post-Conviction Relief for Immigrants

(C)

Travel Advisory.  Any noncitizen, including a Lawful Permanent Resident,  who has any criminal conviction or record, should seek expert immigration advice before traveling abroad for any reason, even briefly.  A permanent resident who is inadmissible might or might not be able to return to the United States after a trip abroad.  An undocumented person who goes home for the holidays, expecting to return illegally, may become permanently ineligible to immigrate through a family member just by leaving the country – even if s/he has no criminal record.[104] Moreover, some safe dispositions are safe only in the Ninth Circuit, so the client should be wary ever if some travel within the United States. See § 10.19.

[104] See Criminal Defense of Immigrants § 18.10.